Thompson v. North American Stainless, LP

Background

Eric Thompson and his fiancée, Miriam Regalado, both worked for the same company. Regalado filed a discrimination charge with the EEOC. Three weeks later the company fired Thompson. Thompson then filed his own charge and sued, claiming the firing was meant to punish Regalado for her complaint. Lower courts disagreed about whether Title VII allows a person in Thompson’s position to sue.

Reasoning

The Court first said that firing Thompson could be unlawful retaliation under the standard from Burlington, which bars employer actions that would dissuade a reasonable worker from filing or supporting a complaint. The Court rejected a categorical rule barring all third-party claims. It then examined the statute’s phrase allowing “a person claiming to be aggrieved” to sue and refused to treat that phrase as coextensive with any injury that satisfies the Constitution. Instead the Court adopted a narrower test drawn from prior decisions: the plaintiff must fall within the statute’s “zone of interests,” meaning the kind of interests Congress meant Title VII to protect. Applying that test, the Court concluded Thompson was not an accidental victim. He had been targeted to harm Regalado, so his injury is the sort Title VII was designed to prevent.

Real world impact

The Court reversed the Sixth Circuit and allowed Thompson to proceed. Employers may now face suits when they retaliate against people closely tied to someone who filed an EEOC charge. The ruling does not create a fixed list of protected relationships; courts will apply an objective test to particular facts.

Dissents or concurrances

Justice Ginsburg, joined by Justice Breyer, emphasized that the EEOC’s compliance manual supports allowing closely related third-party claims, a view the Court’s reasoning accords with.